Compliance Audit Malta: Find the Gaps Before the FIAU Does
FIAU penalties run from €1,000 to €46,500 per breach — and directors face personal liability. A compliance audit identifies where your AML, regulatory or tax obligations are falling short, so you can fix issues on your terms rather than under enforcement pressure.
- AML/CFT, MFSA regulatory and tax compliance audits in a single engagement
- Covers CDD processes, STR reporting, beneficial ownership and risk assessments
- Identifies gaps before FIAU or MFSA supervisory examinations
- Actionable remediation plan with clear timelines and responsibility assignments
Practising auditors and compliance professionals advising MFSA-licensed entities since 2004.
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Established
Practice
Extensive
Regulatory Experience
Proven
Track Record
MFSA
Licensed & Regulated
Your Contacts
Andrew Fenech
Business Development Manager
Adrian Pavia Dimech
Audit Principal
Tatiana Muscat
Audit Manager
Warranted by the Malta Accountancy Board
ACCA & MIA Certified Professionals
Corporate Member of FinanceMalta, MIT & IFSP
Fully GDPR & AMLD-Compliant
Fix Compliance Gaps on Your Terms — Not Under Regulatory Pressure
A compliance audit is a systematic review that verifies whether your organisation meets its legal, regulatory and internal policy obligations. In Malta, this covers a broad range of requirements — from AML/CFT obligations under the Prevention of Money Laundering Act (Cap. 373) to MFSA licensing conditions, tax compliance and internal governance frameworks.
The distinction from a statutory audit is important. A statutory audit examines whether your financial statements present a true and fair view. A compliance audit examines whether your processes, controls and procedures meet the rules that apply to your business. The two serve different purposes, and one does not replace the other.
Malta’s position as an EU financial services hub means regulatory expectations are high. The FIAU uses its CASPAR risk-assessment system to prioritise supervisory examinations, and MFSA conducts AML reviews on the FIAU’s behalf for licensed entities. Companies that wait for a regulatory inspection to discover their gaps tend to face steeper penalties and longer remediation timelines than those that identify issues proactively.
Four Audit Types, One Engagement: AML, Regulatory, Tax and Internal
AML/CFT Compliance Audit
Reviews your adherence to the Prevention of Money Laundering Act (Cap. 373) and the PMLFTR. Covers customer due diligence, suspicious transaction reporting, beneficial ownership verification, risk assessments and staff training. Required for all subject persons: financial institutions, accountants, auditors, company service providers, lawyers involved in financial transactions, and real estate agents.
MFSA Regulatory Compliance Audit
Examines adherence to MFSA licensing conditions and sector-specific rules. Covers governance frameworks, compliance officer functions, internal controls, the Three Lines Model and regulatory reporting. Required for investment firms, banks, insurance intermediaries, payment institutions, VFA service providers and collective investment schemes.
Tax Compliance Audit
Verifies corporate income tax, VAT, provisional tax and transfer pricing obligations. Since January 2024, companies with cross-border intra-group transactions must maintain transfer pricing documentation under S.L. 123.207. The Commissioner for Revenue conducts proactive audits targeting discrepancies, unusual transactions and sectors under increased scrutiny.
Internal Compliance Audit
Assesses internal policies, procedures and controls against your own operational standards. Mandatory for larger MFSA-licensed entities with complex operations. Provides the Board with independent assurance that internal frameworks are working as intended.
Three Audits, Three Purposes — Most Malta Companies Need More Than One
Understanding the differences helps you determine which reviews your entity actually requires.
| Aspect | Compliance Audit | Statutory Audit | Internal Audit |
|---|---|---|---|
| Primary focus | Adherence to laws, regulations, AML/CFT obligations | Accuracy of financial statements | Effectiveness of internal controls |
| Legal basis | PMLA (Cap. 373), MFSA Rules, sector regulations | Companies Act (Cap. 386), Income Tax Management Act | MFSA requirements for licensed entities |
| Scope | CDD, STR, risk assessments, governance, regulatory reporting | Financial reporting, accounting standards, true and fair view | Risk management, governance frameworks, internal processes |
| Who needs it | MFSA-licensed entities, AML subject persons | Most Malta limited liability companies | MFSA-licensed entities with significant operational scale |
| Typical frequency | Annual or risk-based (every 1–3 years) | Annual | Annual or semi-annual for high-risk areas |
MFSA-licensed entities typically require all three audit types. The Three Lines Model places business operations first, compliance and risk oversight second, and internal audit third.
What Non-Compliance Actually Costs: FIAU and MFSA Penalty Ranges
Regulators have clear penalty frameworks. The cost of a compliance audit is a fraction of a single breach penalty.
| Violation Type | Authority | Penalty Range |
|---|---|---|
| AML breach (standard) | FIAU | €1,000 – €46,500 per breach |
| AML breach (serious/systematic) | FIAU | Cumulative penalties, criminal prosecution |
| Director or MLRO personal liability | FIAU | Administrative penalties under Reg. 21(7) PMLFTR |
| MFSA regulatory breach | MFSA | Scoring matrix — up to €72,000+ per breach |
| VAT late registration | Commissioner for Revenue | Up to €250 or 20% of excess output tax |
| Tax fraud or evasion | Commissioner for Revenue | Criminal penalties and imprisonment |
Sources: FIAU Enforcement Factsheet 2021/2022; MFSA Guidance Note on Administrative Penalties methodology. Multiple breaches in a single examination can result in cumulative penalties well above the per-breach maximum.
A proactive compliance audit costs a fraction of a single FIAU penalty. Find out where you stand.
Get My Compliance ReviewIs Your Entity Required to Undergo a Compliance Audit?
Mandatory for MFSA-licensed entities: Investment services firms (Category 2 and 3 licence holders), credit institutions, insurance companies and intermediaries, payment institutions, e-money issuers, VFA service providers, company service providers and collective investment schemes.
Mandatory for AML subject persons: Accountants and auditors conducting relevant activity, lawyers and notaries involved in financial or property transactions, real estate agents, trust service providers, and casinos and gaming operators.
Recommended for: Companies preparing for MFSA or FIAU inspections, entities undergoing M&A transactions or capital raises, businesses expanding into new regulated activities, and any organisation that wants to identify compliance gaps before a regulator does.
Even companies not legally required to undergo a compliance audit benefit from periodic reviews. A voluntary audit demonstrates a proactive compliance culture — something regulators specifically look for during examinations.
From Scoping to Remediation: What Happens in Four Stages
Our compliance audit follows a structured methodology aligned with FIAU and MFSA supervisory processes.
Scoping and Regulatory Mapping
We identify which regulations apply to your entity — PMLA, MFSA licensing conditions, tax rules, GDPR — and assess high-risk areas. You receive a detailed scope document and timeline before fieldwork begins.
Fieldwork and Testing
Our team reviews your CDD files, STR processes, risk assessments, governance frameworks and internal controls. We test samples of customer files, interview key staff and evaluate your compliance systems against regulatory expectations.
Reporting and Risk Rating
Findings are classified by severity — critical, high, medium and low. You receive a detailed report with evidence, root cause analysis and specific recommendations, not generic observations.
Remediation and Follow-Up
We help you build a corrective action plan with clear timelines and responsible parties. Where needed, we conduct follow-up testing to confirm that changes are working before your next regulatory examination.
Scoping and Regulatory Mapping
We identify which regulations apply to your entity — PMLA, MFSA licensing conditions, tax rules, GDPR — and assess high-risk areas. You receive a detailed scope document and timeline before fieldwork begins.
Fieldwork and Testing
Our team reviews your CDD files, STR processes, risk assessments, governance frameworks and internal controls. We test samples of customer files, interview key staff and evaluate your compliance systems against regulatory expectations.
Reporting and Risk Rating
Findings are classified by severity — critical, high, medium and low. You receive a detailed report with evidence, root cause analysis and specific recommendations, not generic observations.
Remediation and Follow-Up
We help you build a corrective action plan with clear timelines and responsible parties. Where needed, we conduct follow-up testing to confirm that changes are working before your next regulatory examination.
Audit, Fix and Prove It — Before the Regulator Arrives
Walk Into FIAU Examinations Prepared
Your audit is conducted by professionals who regularly prepare MFSA-licensed entities for FIAU examinations across investment services, insurance, payments and VFA. You get findings calibrated to what examiners actually look for.
A Remediation Plan You Can Implement Immediately
Every finding comes with a severity rating, root cause analysis and a specific remediation recommendation. No generic checklists — you get a plan with clear owners and timelines ready to execute.
Go From Gaps to Audit-Ready in One Engagement
You are supported from initial findings through remediation to follow-up testing. By the time the regulator arrives, your corrective actions are documented and verified — not still in progress.
One Engagement Instead of Three Separate Firms
AML/CFT, MFSA regulatory and tax compliance reviewed together in a single coordinated engagement. Less duplication, lower total cost, and no gaps between audit scopes.
Compliance Audit Malta: What Directors and MLROs Ask Us
Find Out Where Your Compliance Stands — Before a Regulator Does
Tell us about your entity and the regulations that apply to your business. We will outline the scope of a compliance audit, provide a fee estimate and explain what to expect. No obligation — we typically respond within one working day.
You will speak with
Andrew Fenech
Business Development Manager
Adrian Pavia Dimech
Audit Principal
Tatiana Muscat
Audit Manager
- Free initial consultation
- Response within 24 hours
- No obligations whatsoever
Compliance Audit Malta: Find the Gaps Before the FIAU Does
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